Workers’ Compensation · Primary-source case analysis

New York Central v. White: Workers’ Compensation Could Replace Fault Litigation

By Aneeta Mishra and Timothy Chan

Published May 24, 2026

New York Central Railroad Co. v. White examined an early statute requiring scheduled compensation for accidental workplace injuries without proof of employer negligence.

The statute replaced the former fault rules

The law imposed compensation for covered industrial accidents while limiting the employee to the statutory remedy. The railroad argued that changing common-law rights and defenses deprived it of property without due process.

The new allocation was constitutionally rational

Industrial accidents were a predictable cost of hazardous enterprise. The legislature could place that cost on the industry and spread it through prices rather than leave it on injured workers.

Scheduled benefits supplied a reasonable substitute

The Court considered the remedy’s certainty and structure rather than demanding that statutory compensation reproduce every possible tort recovery.

The judgment sustaining the award was affirmed

The Court rejected the constitutional attack while emphasizing that compensation legislation remains subject to ordinary constitutional limits.

Key takeaways

• Identify the statute governing the injury date.
• Separate statutory coverage from negligence concepts.
• Calculate benefits under the applicable schedule.
• Preserve constitutional arguments without collapsing them into case-specific benefit disputes.